LA’s KCHUNG Radio Demonstrates the Power of Part 15 Broadcasting

This past Sunday the New York Times profiled the Los Angeles cooperative arts-focused station KCHUNG. It isn’t a typical community station, nor is it an LPFM. The station also doesn’t have a license, but it’s not a pirate station.

Instead it operates according to what are generally known as the Part 15 rules, which cover very low-power RF transmissions without a license. These rules cover any electronic device that might emit some kind of radio signal intentionally or unintentionally, from hospital equipment to computers, on any band of the spectrum. The purpose of Part 15 is to put a cap on how much and what kind of radio emissions a device can output, primarily to limit interference with licensed applications.

As I wrote back in 2011, such low-power AM broadcasting can be a little more effective than Part 15 FM. That’s beause the FCC’s FM limits are defined essentially by how powerful the transmission is at 3 meters from the antenna, which puts a pretty hard limit on how far you can broadcast.

Tetsuo Kogawa at the Minneapolis College of Art and Design 2004. Photo: Paul Riismandel

Artist and scholar Tetsuo Kogawa promoted the idea of mini-FM in Japan begining in the 1980s. He put on workshops to help people build their own transmitters. He encourages mini-FM broadcasters to leverage the small broadcast radius by throwing “radio parties,” openly inviting local listeners to drop by and participate in broadcasts.

In the early 90s tiny transmitters based on a single integrated circuit became practical; the storied Ramsey FM–10 was the kit that gave many broadcasters got their start. Kogawa’s work influenced a new generation of transmission artists and community radio activists in the US a decade before LPFM became a reality. Kogawa himself was influenced by the Italian Autonomia free micro-radio movement of the 1970s, as he explains in his article “From Mini-FM to Polymorphous Radio.”

Part 15 Still A Useful Technique

Still, as KCHUNG demonstrates, Part 15 remains a useful approach for broadcasters who aren’t put off by the limited range, or for whom this is actually an advantage. A good reservoir of information about this class of station can be found at Hobby Broadcaster, a site dedicated to “low power AM & FM broadcasting under FCC Part 15 regulations.” It features profiles of more than a dozen Part 15 stations operated by schools, businesses and individuals.

Anyone looking to start a Part 15 station would be well advised to start with a good, rules-compliant transmitter and careful engineering. It can be very easy to exceed the FCC’s limits, which quickly moves your station from legal low-power into pirate radio territory. If someone complains about your souped-up low-power broadcast there’s a chance an FCC enforcement agent may knock on your door.

Beware that just because you can easily buy a transmitter in a store or online doesn’t necessarily mean that it’s actually Part 15 compliant. Last October the FCC upheld an $18,000 fine to Richfield Electronics for selling “The Whole House Tranmitter” which was marketed as a legal low-power transmitter, but exceeded power emission rules. The company said it shipped at least 2,500 of them, but couldn’t track down all the recipients. Caveat emptor.

A Part 15 broadcast could be a nice compliment to an online station, giving it the nice patina of a “real radio station” while potentially serving a few city blocks or a small neighborhood. In a particularly densely populated area a well engineered station could serve dozens of listeners while remaining legal.

The KCHUNG article notes that the station missed last year’s LPFM licensing window, though it doesn’t seem to bother the station’s founder. I suspect that’s because most listners tune in online. But I wonder if the NY Times would pay as much attention to KCHUNG if it didn’t have that real broadcast presence. Thus, another reason why a little Part 15 might spice up an internet station.

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About Paul Riismandel

Paul Riismandel is co-founder and operations director of Radio Survivor. He is also the podcasting evangelist for Midroll Media, serving as producer for The Wolf Den podcast. Paul has more than 20 years of experience in non-commercial radio and instructional media. He is a contributing editor for Streaming Media Magazine, covering the education beat.